Children’s Privacy Policy

Nugget Collective LLC (“NUGGET”, “our”) is committed to protecting the privacy of children who use our Site (as defined in our Terms Of Service, hereinafter the “Terms”) found at Terms Of Service. This CHILDREN’S ONLINE PRIVACY POLICY explains our information collection, disclosure and parental consent practices with respect to information that may be provided by children or about children under the age of 13 (“child” or “children”) and uses terms that are defined in our Privacy Policy, found at Privacy Policy.

We ask that only adults over the age of 18 contact us through our website or by email, and that any personal information provided about a child is provided by a parent or guardian of that child. That said, we understand that sometimes kids can fill out a form on a website, and for that reason we have established this Children’s Privacy Policy (the “Policy”). Our collection of personal information is intended to follow the principles of the Children’s Online Privacy Protection Act (“COPPA”), a law designed to protect the online privacy of children under the age of 13 and it outlines our practices in the United States regarding children’s personal information. For more information on COPPA, please visit https://www.consumer.ftc.gov/articles/0031-protecting-your-childs-privacy-online.

If you have questions or concerns about our privacy practices, please contact us at hello@nugget.travel.

NUGGET offers to its users podcasts and various travel information, among other things, some of which are primarily targeted at children, and others that are intended for users of all ages and their families. Our Site offers a variety of activities, including activities that may collect information about children. Below we summarize potential instances of collection and outline how and when we will provide parental notice and/or seek parental consent if we need to. In the rare instance (if ever) that we may collect personal information directly from a child, we will retain that information only so long as reasonably necessary to fulfill a potential activity request or allow the child to continue to participate in a Site activity, and ensure the security of our users and our services, or as required by law. In the event we discover we have collected information from a child in a manner inconsistent with COPPA’s requirements, we will either delete the information or immediately seek the parent’s consent for that collection.

 

  1. What Information Will We Collect About Children?
    You may voluntarily give us information about your child by filling in forms when using our Services, signing up to our newsletter, or contacting us with e-mail and other similar inquiries. Such information may include your child’s first name, age and city. The foregoing shall be referred to herein as “Personal Data”. We will not collect information directly from children under the age of 13 without obtaining parental consent as outlined in this Policy. If you believe your child is participating in an activity that collects personal information or is submitting personal information to our Site without parental consent, please contact us immediately at hello@nugget.travel.

 

  1. How We use Your Child’s Information
    With your consent, (i) your child’s first name, age and city may be used and made public through the “Go With Nugget” podcast and its supporting materials and (ii) your child’s age may be used and made public under the user profile of Nugget contributors who submit an itinerary. If you would like to revise the information, no longer want to participate, wish to restrict further collection of information and/or no longer want this information stored, please contact us at hello@nugget.travel.

 

  1. About Verifiable Parental Consent
    1. Email Consent: COPPA requires that we seek a parent or guardian’s consent by email in connection with the collection of Personal Data concerning a child. In the email we will explain what information we are collecting, how we plan to use it, how the parent can provide consent, and how the parent can revoke consent. If we do not receive parental consent within a reasonable time, we will delete the parent contact information and any other information collected from the child (or otherwise) in connection with that activity. We will not use parent emails provided for parental consent purposes to market to the parent, unless the parent has expressly opted in to email marketing or has separately participated in an activity that allows for such email contact.
    2. High-Level Consent: In the event NUGGET collects personal information from a child that will be posted publicly, we will seek a higher level of consent than email consent. Such “high-level” methods of consent include but are not limited to requiring a signed consent form by mail, email attachment, or fax.
    3. Teacher consent in lieu of a parent: With regard to school-based activities, COPPA allows teachers and school administrators to act in the stead of parents to provide consent for the collection of personal information from children. Schools should always notify parents about these activities. For more information on parental rights with respect to a child’s educational record under the Family Educational Rights and Privacy Act (FERPA), please visit https://www2.ed.gov/policy/gen/guid/fpco/ferpa/index.html.

 

  1. What Are My Parental Rights?
    • In the rare event we collect information directly from your child, we will not require a child to disclose more information than is reasonably necessary to participate in an activity;
    • You can review your child’s personal information, direct us to delete it, and refuse to allow any further collection or use of the child’s information;
    • You can agree to the collection and use of their child’s information, but not allow disclosure to third parties.Please contact us at hello@nugget.travel to exercise any of your rights as outlined above.

 

  1. Email Contact with a Child
    On occasion, in order to respond to a question or request from a child, NUGGET may need to ask for the child’s online contact information, such as an email address. NUGGET will delete this information immediately after responding to the question or request.
    We do not collect a child’s online contact information for any ongoing communications such as our newsletter, which is directed at adults and not children (anyone signing up for newsletter should be be 18 years of age or older). If you suspect that your child has signed up for our newsletter, please contact us at hello@nugget.travel to request deletion of any of your child’s information and/or to opt out of the newsletter.

 

  1. How You Use our Site (Analytics & Cookies) and Collection of Aggregated Information

    When children interact with us, certain information may automatically be collected, both to make our Site more interesting and useful to children and for various purposes related to our business.Our Site uses cookies and other mechanisms, such as a web beacon, to collect and log analytical information, to keep users logged in, to help analyze how visitors use the Site and to compile statistical reports on Site activity. This processing is crucial to the running of our online business. This information is not used to develop a personal profile of you. To find out more about the use of cookies, please visit http://www.allaboutcookies.org/.

    We use Google Analytics. When you visit our Site (regardless if you are an Account holder or unregistered user), these analytics service providers may collect the following data, which for the avoidance of doubt, may be in the form of a text file stored on your computer or device through your web browser, but such data will be anonymized and aggregated before reporting back to us. However, if you have an Account, the cookies may identify that your web browser has accessed aspects of our Services and may associate the information with your Account:

    • number of visitors to our Site;
    • pages visited while at the Site and time spent per page;
    • page interaction information, such as scrolling, clicks and browsing methods;
    • websites where visitors have come from and where they go afterwards;
    • page response times and any download errors; and
    • other technical information relating to end user device, such as IP address, browser type, or browser plug-in.

    This analysis is fundamental to the running of our online business and we therefore undertake such monitoring in the pursuit of our legitimate interests in improving our Site, and to provide and improve the Service and source of information to visitors. This may include allowing third party advertisements to be served to you through the Services, such as through a banner or pop up ad, by a third-party advertising agency, network, or research firm, with such advertisements sometimes targeting to a user who fits a certain general profile category and may be based on anonymized information, which could include Personal Data (gender, age, etc.), Site usage patterns, or activity with third-party services. Notwithstanding the foregoing, we do not provide Personal Data to such third-parties for use outside of the Services.

    Notwithstanding the foregoing, many web and mobile browsers have an option for turning off cookie feature(s), which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. In connection with viewing the Site to enable you to take advantage the most attractive features of the Services, we recommend that you leave cookies active as we believe they will likely improve your experience.

    To find out more about Google Analytics and to learn how to opt out, please visit:

    In the event we collect (or allow others to collect) such information from children on our Site for other purposes, we will notify parents and obtain consent prior to such collection.

    Please contact us at hello@nugget.travel with questions about the operators’ privacy policies and collection and use practices.

 

  1. When Is Information Collected From Children Available to Third Parties?

    We keep your information confidential, but may disclose it to our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Policy. If we provide your child’s Personal Data to third parties, we shall only do so provided that they do not make independent use of the information and provide the same confidential treatment as we do.We only permit them to process your child’s Personal Data for specified purposes and in accordance with our instructions. All our third-party service providers are required to take appropriate security measures to protect your child’s Personal Data. Activities which are carried out by or in collaboration with third party service providers include our website hosting and our fulfilment service provider.

    In addition, we may disclose your child’s Personal Data to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

    If we are involved in a merger, acquisition, or sale of all or a portion of our business or assets, the child’s Personal Data we hold may be included as part of that sale, in which case you will be notified via email, your account and/or a prominent notice on the Site of any changes in ownership or use of your information, as well as any choices you may have regarding that information.

    Lastly and for the avoidance of doubt, some of your child’s activities through the Services may be public by default, including, without limitation posting user-generated content publicly to certain areas of the Site and publicly-accessible information via your Account page. PLEASE DO NOT POST OR UPLOAD ANY OF YOUR CHILD’S INFORMATION TO THE SERVICES IN A PUBLIC WAY THAT YOU DO NOT WANT PUBLICLY AVAILABLE. In the event that you wish any child-related information to be removed from the Services, we will accommodate you or your child in accordance with COPPA. Please email us at: hello@nugget.travel. For more information, please see our user-generated content provisions in our Terms.

    Except as provided above and in our Terms and Privacy Policy, we will not provide your or your child’s information to third parties unless we receive consent.

Effective Date of Nugget’s Children’s Privacy Policy: August 29, 2019.